Privacy Policy

1. Introduction

gembet ("gembet", "we", "us", "our") is committed to protecting and respecting the privacy of individuals who use the gembet platform ("the Service") accessible at gembet.lat. This Privacy Policy ("Policy") explains what personal data we collect from Members and visitors, how we use and protect that data, the legal bases on which we process it, and the rights available to you in relation to your personal data.

This Policy applies to all personal data processed by gembet in connection with the registration, maintenance, and use of gembet Accounts, as well as data collected through visitors' use of the gembet website. By accessing the Service or creating an Account, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy should be read alongside gembet's Terms & Conditions, which govern your use of the Service more broadly.

2. Data Controller

For the purposes of applicable data protection legislation, gembet is the data controller responsible for personal data collected through the gembet platform. If you have any questions about how gembet handles your personal data, you may contact our data protection contact at: [email protected] (plain text — not a clickable link).

3. Data We Collect

3.1 Registration and Account Data

When you register a gembet Account, we collect the following categories of personal data:

• Full legal name as stated on your government-issued identity document;
• Date of birth (for age verification — gembet is strictly 21+ only);
• Malaysian mobile phone number;
• Email address;
• Residential address;
• Username and encrypted password (passwords are stored in hashed form and are never accessible to gembet staff in plain text).

3.2 Identity Verification (KYC) Data

To comply with anti-money laundering obligations and to verify eligibility, gembet may collect:

• Copy of Malaysian National Identification Card (MyKad) or valid passport;
• Proof of residential address (utility bill, bank statement, or equivalent document);
• Proof of payment method ownership (for example, a screenshot of your Touch 'n Go eWallet or Maybank account showing your name).

3.3 Financial Transaction Data

We collect records of all financial transactions conducted through your gembet Account, including deposit amounts, withdrawal amounts, dates, payment method references, and Account balance history. We do not store full payment card numbers; payment processing is handled by our third-party payment service providers subject to their own security standards.

3.4 Gaming Activity Data

We collect records of your gaming activity on the gembet platform, including games played, wagers placed, outcomes, session durations, and responsible gaming tool usage. This data is used for account management, dispute resolution, fraud prevention, and regulatory compliance purposes.

3.5 Technical and Usage Data

When you access the gembet website, we automatically collect certain technical data including your IP address, browser type and version, operating system, device identifiers, referring URL, pages viewed, and session timestamps. This data is collected through server logs and cookies as described in Section 8.

3.6 Communications Data

If you contact gembet through live chat, email, or any other communication channel, we retain records of those communications for customer service quality, dispute resolution, and compliance purposes.

4. How We Use Your Data

gembet uses the personal data we collect for the following purposes:

Purpose	Data Used
Account registration and management	Registration data, contact details
Identity verification and age confirmation (21+)	KYC documents, date of birth
Processing deposits and withdrawals	Financial transaction data, payment method details
Providing gaming and betting services	Account data, gaming activity data
Fraud prevention and security monitoring	Technical data, transaction data, gaming activity
Anti-money laundering compliance	KYC data, financial transaction data
Customer support and dispute resolution	Communications data, account data, gaming records
Responsible gaming monitoring and enforcement	Gaming activity data, responsible gaming tool usage
Service improvement and analytics	Technical and usage data (aggregated)
Promotional communications (with consent)	Contact details, gaming preferences

5. Legal Basis for Processing

gembet processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between gembet and you as a Member — including account management, transaction processing, and service delivery;
• Legal obligation: Processing required to comply with applicable anti-money laundering laws, gaming regulations, age verification requirements, and other legal obligations to which gembet is subject;
• Legitimate interests: Processing conducted for gembet's legitimate business interests, including fraud prevention, security monitoring, service improvement, and responsible gaming compliance, where those interests are not overridden by your data protection rights;
• Consent: Processing conducted on the basis of your explicit consent, including for direct marketing communications. You may withdraw your consent at any time by contacting gembet support or updating your Account settings.

6. Data Sharing and Third Parties

6.1 Payment Service Providers

gembet shares financial transaction data with our payment service providers — including the operators of Touch 'n Go eWallet, Boost, and Malaysian banking institutions (Maybank, CIMB, Public Bank) — solely to the extent necessary to process your deposits and withdrawals. These providers process your data under their own privacy policies and applicable financial data protection standards.

6.2 Game Content Providers

Some personal data (such as session tokens and Account identifiers) may be transmitted to our licensed game content providers (including live casino studio operators and slot game providers) as technically necessary to operate the games you play. These providers do not receive your full personal profile and process data under confidentiality obligations.

6.3 Regulatory and Law Enforcement Authorities

gembet may disclose personal data to regulatory bodies, law enforcement agencies, or other public authorities where required to do so by applicable law, court order, or legitimate regulatory request. In such cases, gembet will disclose only the minimum data required to satisfy the relevant legal obligation.

6.4 No Sale of Personal Data

gembet does not sell, rent, licence, or otherwise transfer your personal data to third-party marketers, data brokers, or advertising networks. Your data is not monetised through third-party commercial relationships.

6.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of gembet's business, personal data held by gembet may be transferred to the acquiring entity as part of that transaction, subject to the same level of data protection as described in this Policy.

7. Data Retention

gembet retains personal data for the following periods:

• Account and KYC data: Retained for a minimum of five (5) years following Account closure, as required by anti-money laundering regulations applicable to licensed gaming operators;
• Financial transaction records: Retained for a minimum of five (5) years following the date of each transaction;
• Gaming activity records: Retained for three (3) years following Account closure, or longer where required for dispute resolution or regulatory purposes;
• Communications records: Retained for three (3) years following the date of the last communication;
• Technical and usage data: Retained for twelve (12) months from collection, after which it is anonymised or deleted.

Where data is no longer required for the purposes for which it was collected and no legal retention obligation applies, gembet will securely delete or anonymise that data.

8. Cookies and Tracking Technologies

8.1 What Cookies We Use

The gembet website uses the following categories of cookies:

• Strictly necessary cookies: Essential for the operation of the platform — including authentication, session management, and security functions. These cannot be disabled without preventing use of the Service;
• Functional cookies: Used to remember your preferences, such as language settings and account display options;
• Analytics cookies: Used to collect aggregate, anonymised data about how visitors use the gembet website — including pages visited, session duration, and navigation patterns. This data is used solely to improve the Service and is not linked to individual Member profiles.

8.2 What We Do Not Use

gembet does not use third-party advertising cookies, cross-site tracking pixels, or retargeting technologies. No data collected through gembet cookies is shared with third-party advertising platforms.

8.3 Managing Cookies

You may configure your browser to block or delete cookies. Note that disabling strictly necessary cookies will prevent you from logging in to your gembet Account and using the Service. Instructions for managing cookies are available in the help documentation of your browser.

9. Data Security

gembet implements technical and organisational security measures appropriate to the sensitivity of the personal data we process:

• All data in transit between your browser and the gembet platform is encrypted using 256-bit SSL/TLS;
• Personal data stored on gembet servers is encrypted at rest using AES-256 encryption;
• Access to personal data within gembet is restricted to authorised personnel on a need-to-know basis, with access controls and audit logging in place;
• gembet conducts regular security assessments and penetration testing of its platform infrastructure;
• Passwords are stored in hashed form using industry-standard cryptographic hashing algorithms — gembet staff cannot access your password in plain text.

Notwithstanding these measures, no data transmission over the internet or storage system can be guaranteed to be 100% secure. gembet encourages Members to use strong, unique passwords and to enable two-factor authentication from their Account security settings.

10. Your Data Rights

Subject to applicable data protection law and legal retention obligations, you have the following rights in relation to your personal data held by gembet:

• Right of access: You may request a copy of the personal data gembet holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data;
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to restriction: You may request that gembet restricts processing of your data in certain circumstances;
• Right to object: You may object to processing carried out on the basis of legitimate interests;
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, contact gembet at: [email protected]. gembet will respond to data rights requests within thirty (30) days. We may require identity verification before processing any data rights request.

11. Children and Minors

The gembet Service is strictly intended for individuals aged 21 years and above. gembet does not knowingly collect personal data from individuals under the age of 21. Where gembet becomes aware that personal data has been collected from an individual under 21, that data will be deleted promptly and the associated Account closed in accordance with the gembet Terms & Conditions. If you believe a minor has registered a gembet Account, please contact us immediately at: [email protected].

12. Third-Party Links

The gembet platform does not contain links to third-party websites. In the event that any third-party content or integrations are present, gembet is not responsible for the privacy practices of those third parties, and this Policy does not apply to data collected by third-party services or websites. We encourage you to review the privacy policies of any third-party services you use in connection with online gaming.

13. Policy Updates

gembet reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or platform operations. Material changes to this Policy will be communicated to registered Members via the email address registered to their Account. The "Last updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the gembet Service following any update constitutes acceptance of the revised Policy.

14. Contact and Complaints

If you have any questions, concerns, or complaints about how gembet processes your personal data, please contact our support team in the first instance. Our support team is available 24/7 via live chat from within your Account dashboard. You may also contact us by email at: [email protected] — please include your Account username in all privacy-related enquiries to assist us in identifying your records and responding promptly.